SIMPSON THACHER & BARTLETTLLP
425 LEXINGTON AVENUE
NEW YORK, N.Y. 10017-3954
(212) 455-2000
FACSIMILE (212) 455-2502
VIA EDGAR
April 20, 2009
| Re: | SunGard Data Systems Inc. | |||
| and Subsidiary Guarantors | ||||
| Registration Statement on Form S-1 |
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of SunGard Data Systems Inc., a Delaware corporation (the “Company”) and the subsidiary guarantors (collectively with the Company, the “Registrants”), we hereby transmit for electronic filing, pursuant to Rule 101(a) of Regulation S-T of the Securities Act of 1933, as amended (the “Securities Act”), a Registration Statement on Form S-1 (the “Registration Statement”), which contains a market-maker prospectus for use by Goldman, Sachs & Co., an affiliate of the Registrants, in connection with its market-making activities for the Company’s 9 1/8% Senior Notes due 2013, 10 5/8% Senior Notes due 2015 and 10 1/4% Senior Subordinated Notes due 2015 and the related guarantees of each. The disclosure contained in the Registration Statement is substantially similar to the disclosure contained in a Registration Statement on Form S-1 that was filed by the Company with the Securities and Exchange Commission (the “SEC”) on April 22, 2008 and declared effective by the SEC on May 13, 2008. The Registration Statement is being filed solely to update the information, including financial statements and other information for the year ended December 31, 2008, in the previous Registration Statement on Form S-1 referred to above, to remove and add certain guarantors, as appropriate, as Registrants and to add the 10 5/8% Senior Notes due 2015 as an additional series of notes registered under the Form S-1.
Pursuant to Rule 457(q) under the Securities Act, no filing fee is required.
Should you have any questions regarding this filing, please do not hesitate to contact Richard A. Fenyes at (212) 455-2812.
Very truly yours,
/s/ Simpson Thacher & Bartlett LLP
SIMPSON THACHER & BARTLETT LLP
| cc: | Victoria E. Silbey, Esq. |